A salesperson's brokerage receives a $25,000 deposit from one client in three cash payments: $8,000 and $9,000 on Monday morning, and $8,000 on Wednesday. What FINTRAC reporting obligation applies?
Correct Answer
A) File a Large Cash Transaction Report under the 24-hour rule
Under FINTRAC's 24-hour rule, a Large Cash Transaction Report is required when a reporting entity receives two or more cash amounts totalling $10,000 or more within a consecutive 24-hour window and knows they are conducted by or for the same person. The Monday payments total $17,000, so they must be reported within 15 calendar days; the Wednesday payment falls outside that window. If the pattern gives reasonable grounds to suspect structuring, a Suspicious Transaction Report is also required.
Why This Is the Correct Answer
This answer is correct because two cash payments from the same client totalling $17,000 were received within 24 consecutive hours. FINTRAC's 24-hour rule treats them as a large cash transaction, so the brokerage must submit a Large Cash Transaction Report within 15 calendar days.
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